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    <title>2025 (8) TMI 33 - ITAT DELHI</title>
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    <description>A reassessment addition cannot be sustained when the reopening was initiated on one recorded reason but the final addition was made on a different issue. Here, reassessment was opened on the basis of alleged acquisition of capital assets or purchase of immovable property, yet the assessment ultimately added alleged capital gains from a sale transaction. Because no addition was made on the recorded reopening ground, the impugned addition was held unsustainable and was deleted, with the assessee succeeding on the reassessment challenge.</description>
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      <link>https://www.taxtmi.com/caselaws?id=775846</link>
      <description>A reassessment addition cannot be sustained when the reopening was initiated on one recorded reason but the final addition was made on a different issue. Here, reassessment was opened on the basis of alleged acquisition of capital assets or purchase of immovable property, yet the assessment ultimately added alleged capital gains from a sale transaction. Because no addition was made on the recorded reopening ground, the impugned addition was held unsustainable and was deleted, with the assessee succeeding on the reassessment challenge.</description>
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